Federal Income Taxation of Insurance Companies, Fourth Edition

Federal Income Taxation of Insurance Companies, Fourth Edition, provides a comprehensive analysis of life and nonlife insurance company taxation in the United States, including corporate tax issues, the taxation of captive insurance arrangements, and provisions related to special health insurance providers. Highlights of the new Fourth Edition include: analysis of the shift from the use of formulaic reserve rules to the use of numerous factors, including stochastic factors, under the new Principle-Based Reserving (PBR) rules applied by life insurers to compute reserves for many contracts; new alternative tax rules for qualified property and casualty insurers under section 831(b) that increase the limit on an insurer s direct written premiums and impose diversification requirements that insurers must satisfy; amended section 833(c)(5) and related Treasury Regulations that conform the Medical Loss Ratio (MLR) to the ratio that influences the rebate a Blue Cross/Blue Shield organization would have to pay if its MLR is too low under non-tax rules added by the Affordable Care Act; court decisions that address important insurance company tax principles, including the continuing significance of the investor control doctrine, in Webber v. Commissioner, and the qualification of coverage as insurance by a captive, in Rent-A-Center v. Commissioner, when the captive's liabilities were guaranteed for as much as millions of dollars; and other court decisions and IRS pronouncements that will enable tax specialists to address many difficult insurance company tax issues. The Appendices to the edition also include tables of statutes, treasury regulations, cases, IRS pronouncements, and written determinations, as well as a full index.